We have some clients who are looking to buy some CRA-eligible mortgage loans and are trying to determine eligibility.

1) Are mortgages eligible for CRA credit beyond the year of origination (if income or census-tract qualified)? My assumtion is yes, but if for some reason I have missed this fundamental assumption, ignore the rest.

2) If a loan was made in 2008, but is sold to another bank in 2012, what income and census tract information is used for eligibility? For income, is it just at origination? For census tract, is it the nature of the tract at origination (distressed, LMI, etc.) or at time of purchase by the second bank?

Thanks!

Don

Have any of you ever bought loans (I'm thinking mortgages in particular) from another institution for CRA purposes?

Don't know how the other regulators would view it, but here is the OCC position, as communicated to me:

Income: for a loan originated that long ago, no income credit will be considered or given

Geography: the census tract as of the date of purchase is what will govern (along with the income level of the tract as of the date of purchase)

So, if you're buying old loans for CRA credit, make sure you check the property addresses against the 2012 census tract information.

Thanks, that's very helpful. I appreciate it.